The client is a multi-sited international employer, employing over 170,000 people worldwide, manufacturing products for the home and personal care market. The UK production facilities vary in size and have a number of sites that fall within the scope of the Control of Major Accident Hazards (COMAH) Regulations 1999 (as amended).
One of the client’s top tier COMAH sites was considering the reduction in the manning levels of the Health, Safety and Environmental (HS&E) team. Santia was asked to undertake a proactive, independent Management of Change review specifically for this potential organisational change. In particular, the client wanted to establish if it was realistic for the size of the team to be reduced without compromising the need to perform existing required functions and if such a reduction constituted a ‘Significant Change’ as defined in the COMAH Regulations – the implications being a required amendment to the sire Safety Report.
The client had an existing organisational change procedure but this only dealt with ‘direct contact’ with major hazard risks. However, this work was based more on the indirect effects of the change and therefore was more complex.
The outcome of the Management of Change review would either support or oppose the reduction in the manning level.
Santia has undertaken a significant amount of auditing of company systems, including the Management of Change procedures for over five years working for this client and in doing so has developed an on-going, trusting partnership and a deep understanding of major hazards and the management of them within the client’s business.
The review required a number of specific tasks to be undertaken to assess the impact of this potential change. These were;
Work plan review. The existing work plan for the whole team was reviewed to ensure it effectively managed the risks for a top tier COMAH site.
Review of Competent Authority’s Intervention plan and the site’s Safety Report commitments. The intervention plan and safety report were reviewed to ensure the work plan took into consideration the proactive interventions planned by the Competent Authority. It was noted that the Competent Authority was applying a ‘light touch’ regarding intervention at this site due to its excellent and responsive proactive management of major hazards.
Time and motion study. A study was undertaken to assess the actual time taken by each member of the HS&E team to deliver the activities within the work plan. These were then assessed to ensure they represented realistic time periods.
Work plan mapping. The time periods required and activities were then mapped onto the HS&E team members to determine the utilisation of each team member.
Interviews with HS&E team members. All team members were interviewed to assess whether they perceived the time available allowed them to effectively manage the existing workload.
The Review found the following;
The Health, Safety and Environmental work plan required over 99% of the HS&E team’s existing capacity to proactively manage the sites COMAH activities.
There remained no capacity for unplanned work (reactive) without delaying the planned and required proactive work.
All HS&E team members have had to delay elements of their planned work, mainly non-COMAH matters. under the existing manning levels.
Any drop in team size would constitute a ‘Significant Change’ and therefore require a formal modification to the Safety Report.
In the world of fast moving consumer goods manufacturing, the site has been, and continues to be subject to significant plant and equipment upgrades, as well as changes due to new product ranges. This has resulted in a gradual overloading of the HS&E team capacity, and is the main reason why planned work has had to be delayed or postponed.
As a result of the Management of Change review, conducted by Santia the client decided that the proposed change was not viable unless it was to commit to the use of external support to meet its Health, Safety and Environmental commitments.